15 August 2025
On August 13, 2025, the U.S. Administration issued an Executive Order titled “Enabling Competition in the Commercial Space Industry”. The Order aims to ease federal regulation of the commercial space industry and includes provisions to speed the licensing process for rocket launches. It directs the Secretary of Transportation to review regulatory requirements and “eliminate outdated, redundant, or overly restrictive rules for launch and reentry vehicles.”
Launch is an integral phase of the spacecraft life cycle, and we recognize a continuum of environment from Earth to space. Therefore, actions intended to further activities in space beginning on Earth are actions taken toward both the terrestrial and space environments.
Launches affect the environment, disrupting wildlife habitats and degrading quality of life in nearby communities. Concerns involving the pollution of air, water and soil exist. There is a non-negligible potential for accidents around liftoff, including explosions of highly volatile fuels. During the ascent phase, rockets emit considerable black soot particulates at low altitudes and water vapor at middle altitudes.
Before performing major federal actions, such as launching from spaceports, agencies must assess the environmental, cultural, and economic consequences of the action and alternatives. In the review process established by the National Environmental Policy Act (NEPA), agencies evaluate such effects and provide opportunities for public review and comment. Each federal agency additionally maintains a short list of “categorical exclusions” that circumvent NEPA reviews. No space company has to date demonstrated any inability to comply with the findings and orders associated with previous environmental reviews.
In the face of increasing space launches, and lacking years of precedents and environmental data, this is no time to turn away from the science of evaluating potential harms and deregulating the space industry.
Statement of the CSE position
We advocate for the health of the earth-space continuum, and spaceports represent much of that continuum. Therefore, the Center for Space Environmentalism takes the position that the Administration should not exempt activities at spaceports from mandated environmental review.
We further oppose any changes to the Federal Aviation Administration (FAA)’s Office of Commercial Space Transportation or the Office of Space Commerce that would make its leadership tied politically to this or any future President. Space-based capabilities have demonstrated the power to turn the tide of wars and affect the livelihood of individuals in sovereign nations, via, e.g., broadband Internet connectivity, dual-use technologies, and reliable remote sensing imagery. A political appointee in this role would represent an outsized position of power able to disrupt continuity and unnecessarily politicises space activity. The U.S. civil service was established in part to insulate core functions of government from the whims of politics. Oversight of space is increasing a core function of government and should therefore also be insulated from the shifting winds of politics.
Prior to this Executive Order (EO), NEPA evaluations conducted by the FAA were not thorough enough to consider aggregate effects. In light of EO 14154 revoking the regulatory authority of the Council on Environmental Quality (CEQ)1 and recent cuts to the Environmental Protection Agency’s Research and Development Office,2 we call upon the FAA to codify and broaden the prior scope of their NEPA evaluations. This broadening must consider aggregate effects of multiple launches and utilizing evaluations that are no older than five years in future Environmental Assessments (EAs), as the commercial space industry rapidly changes from year to year.3 We stand with the 620 EPA signatories of the open letter of dissent and offer this EO as further evidence of “ignoring scientific consensus to benefit polluters.”4
Finally, we call for an increase in staff at the FAA to perform EAs, as the FAA was over-strained prior to this EO and many probationary employees performing this service have been terminated by unlawful reductions in force (RIFs).5
Local- and state-level opposition to aspects of spaceport launch facilities have cited environmental concerns. Three SpaceX Starship rockets launched in 2025 alone exploded after liftoff,6,7 raining debris down on Caribbean island nations,8 leaving debris in the water and on tourist beaches. During a failed test in January 2025, commercial airliners were forced to divert in order to avoid debris raining down after an explosion.9 Another Starship rocket exploded on its test stand in preparation for launch.10 Destruction has also occurred on the ground at the SpaceX facility at Boca Chica.11 Wildlife habitat has been damaged or destroyed, including the ocelot coastal corridor, developing on endangered wetlands, and rapidly degrading the habitat of the endangered snowy plover.12 The concrete launch pad was obliterated in a test that scorched nearby birds’ nests, resulted in a three-acre wildfire, and punched concrete chunks hundreds of feet from the landing site.13 Alleged violations of the Clean Water Act have occurred, including discharge of tens of thousands of gallons of liquid oxygen and millions of gallons of deluge water into adjacent wetlands.14 Noise and vibration from launches have caused damage to nearby homes and quality of life for area residents.15,16,17
Public opposition to spaceports on environmental grounds is growing. This results from a diversity of effects observed in and around spaceports specifically attributable to launch activities. For example, SpaceX situated the Town of Starbase, Texas, and the Boca Chica launch site in endangered wetlands despite a record 114 environmental flags in an FAA-mandated environmental review.18 Fearing harm to nearby beaches, the California Coastal Commission denied Vandenberg Space Force Base’s request to increase the number of SpaceX launches; now, the Commission is battling two lawsuits resulting from that decision.19 Planned SpaceX operations near Hawaii are expected to have a variety of harmful effects on various species of whales, turtles, seals, fishes, sharks, corals and other sea life.20 The National Marine Fisheries Service identified three specific sea turtle species – green, Kemp’s ridley and loggerhead – as potentially “adversely affected” by sonic booms, falling debris and spills of materials like fuel and oil.21 Also in the Pacific Ocean, plans to build two landing pads at Johnson Atoll were met with backlash from wildlife experts and representatives of Indigenous communities.22
This EO is a response to increasing demand for faster licensing turnaround, which has been demonstrated to be caused by FAA staffing shortages, an unprecedented number of license modifications, a record number of mishap investigations, and the unique licensing protocols for novel space activities.23 Other sources of spaceport bottlenecks have been demonstrated to arise from imbalanced access to privately owned launch sites versus government ranges, improperly forecasted launch demands, and unclear best practices for spaceport management.24 It has not been reported that licensing delays are caused by environmental evaluations apart from an investigation into the destruction of a SpaceX launch pad and a SpaceX proposal to develop endangered wetlands for a spaceport base, which resulted in the environmental research and publication of 117 recommended mitigation measures.25 Federal, state, and local stakeholders have spoken out about space launch debris, sonic booms, and poor economic foresighting, such as in the case of Boca Chica, Texas; Johnston Atoll; Vandenberg, California; Camden, Georgia; Mokumanamana, Hawaii; and the Turks and Caicos Islands
This EO suggests adding space activities to the list of “categorical exclusions”, which are actions that do not require a NEPA review in the future. An EIS database review of FAA Environmental Assessments (EAs) related to spacecraft launch shows evaluations already commonly result in a FONSI. This is due to the fact EAs are conducted in a narrow scope, limited to mission type and launching service; and they are approved on the basis of a rate per year. As such, EAs do not adequately take into account the contribution of the proposed action to aggregate effects of industry-wide increases in launch cadence or the effect launches in more rapid succession might have. Circumventing further EAs by adding activities to the list of Categorical Exclusions ignores the exponential growth of the space industry and already early warning signs of destruction and commercialization that is not risk or failure adverse.
All EAs under NEPA are suggested actions to mitigate economic, cultural, and ecological harm. The options presented by a NEPA review also include the “no action alternative,” suggesting the consequences of a course of action in which no mitigations are taken. NEPA is not regulatory, nor is it binding: it is a fact-finding analysis. It is dangerous to the American people and shared, intertwined ecosystems across the world to not evaluate these outcomes. Importantly, the NEPA process includes a period of public comment, which would be circumvented altogether for actions that are considered “categorical exclusions.”
The executive order potentially infringes the sovereignty of U.S. states by forcing them to permit launches from their territories in contravention of their own environmental laws. States are subject to the Coastal Zone Management Act (CZMA),26 a voluntary partnership between the federal government and coastal states and territories that encourages coastal states to develop and implement management programs to balance economic development and environmental protection within their coastal zones. The CZMA requires that Federal actions that are reasonably likely to affect any land or water use or natural resource of the coastal zone be consistent with enforceable policies of a State's federally-approved coastal management program.27
Reuters recently reported that in September 2022, during an offensive led by Ukraine to retake territory previously captured by Russia in the ongoing Russo-Ukrainian War, SpaceX CEO Elon Musk “gave an order that disrupted the counteroffensive and dented Kyiv’s trust in Starlink, the satellite internet service the billionaire provided early in the war to help Ukraine’s military maintain battlefield connectivity.”28 According to the Reuters reporting, Musk was personally involved in making the decision to cut service to the Ukrainian military: “According to three people familiar with the command, Musk told a senior engineer at the California offices of SpaceX … to cut coverage in areas including Kherson, a strategic region north of the Black Sea that Ukraine was trying to reclaim.” This episode shows that a single space actor providing service to foreign military customers – potentially including U.S. adversaries – can at the least impact, and at worst contradict or thwart, American foreign policy goals.
Notes
1. 2025-01956 (90 FR 8353). https://www.federalregister.gov/documents/2025/01/29/2025-01956/unleashing-american-energy
2. Daly, M. (2025, July 19). “EPA eliminates research and development office as it begins thousands of layoffs”. PBS News. https://www.pbs.org/newshour/politics/epa-eliminates-research-and-development-office-as-it-begins-thousands-of-layoffs
3. 2025-03014 (90 FR 10610). https://www.federalregister.gov/documents/2025/02/25/2025-03014/removal-of-national-environmental-policy-act-implementing-regulations
4. https://www.standupforscience.net/epa-declaration
5. Katz, E. (2025, May 15). “The Trump administration is staffing up parts of FAA, it’s also incentivizing thousands of departures and threatening layoffs”. Government Executive. https://www.govexec.com/management/2025/05/trump-administration-staffing-parts-faa-its-also-incentivizing-thousands-departures-and-threatening-layoffs/405347/
6. Dunn, M. (2025, March 6). “SpaceX’s latest Starship test flight ends with another explosion”. Associated Press. https://apnews.com/article/spacex-starship-elon-musk-0c260a324f597a172300315c6486b9df accessed 25 July 2025
7. Dunn, M. (2025, May 28). “SpaceX launches another Starship rocket after back-to-back explosions, but it tumbles out of control”. Associated Press. https://apnews.com/article/spacex-starship-elon-musk-moon-mars-5f02ab8e4b794e518fe99905adaa7471
8. Wattles, J. (2025, January 17). “Regulators are investigating reports of property damage from SpaceX Starship’s explosion”. CNN. https://edition.cnn.com/2025/01/17/science/spacex-starship-explosion-investigation
9. Roulette, J. (2025, January 17). “SpaceX's Starship explodes in flight test, forcing airlines to divert”. Reuters. https://www.reuters.com/technology/space/spacex-launches-seventh-starship-mock-satellite-deployment-test-2025-01-16/
10. Yoon, J. (2025, June 19). “SpaceX Starship Rocket Explodes Before Test”. New York Times. https://www.nytimes.com/2025/06/19/us/spacex-rocket-explosion-texas.html
11. q.v. Wilcox, D. (2024) “The Terrible Irony of Destroying Earth in Search of Plan(et) B: SpaceX’s Impacts to Boca Chica, Texas” Defenders of Wildlife. https://defenders.org/blog/2024/10/terrible-irony-of-destroying-earth-search-of-planet-b-spacexs-impacts-boca-chica-0
12. American Bird Conservancy (2022, June 13). “SpaceX's Harm to Wildlife in Texas Set to Continue, Due to FAA Decision”. https://abcbirds.org/news/spacex-faa-announcement-june-2022/
13. Davila, G. (2023, May 5). “SpaceX Explosion Damages Environment Around Launch Site” NPR Science Friday. https://www.sciencefriday.com/segments/spacex-explosion-launch-debris/
14. q.v. “Public Notice: Proposed Administrative Penalty Order against Space Explorations Technologies Corp. (SpaceX) for Clean Water Act violation” (10 September 2024). https://web.archive.org/web/20240912010709/https://www.epa.gov/tx/proposed-administrative-penalty-order-against-space-explorations-technologies-corp-spacex-clean.
15. Solon, O. (2021, December 8). “Disgruntled neighbors and dwindling shorebirds jeopardize SpaceX expansion”. NBC News. https://www.nbcnews.com/tech/tech-news/disgruntled-neighbors-dwindling-shorebirds-jeopardize-spacex-expansion-rcna7792
16. Koren, M. (2023, April 27) “The Messy Reality of Elon Musk’s Space City”. The Atlantic. https://www.theatlantic.com/science/archive/2023/04/spacex-starship-explosion-dust-debris-texas/673881/
17. Lipton, E. (2024, November 18). “SpaceX Starship’s Sonic Boom Creates Risk of Structural Damage, Test Finds”. New York Times. https://www.nytimes.com/2024/11/18/us/politics/spacex-starship-sonic-boom-damage.html
18. Koren, M. (2023, April 27). “The Messy Reality of Elon Musk’s Space City”. The Atlantic. https://www.theatlantic.com/science/archive/2023/04/spacex-starship-explosion-dust-debris-texas/673881/ As a point of comparison, similar sites usually elicit around half a dozen environmental flags.
19. Lanham, C. (2025, January 23). “California Coastal Commission faces two lawsuits after denying Vandenberg’s request to increase SpaceX launches”. Santa Maria Sun. https://www.santamariasun.com/news/california-coastal-commission-faces-two-lawsuits-after-denying-vandenbergs-request-to-increase-spacex-launches-16251401
20. United States. National Marine Fisheries Service. Office of Protected Resources. (2025). “Reinitiated FAA SpaceX Starship-Super Heavy Increased Launch Cadence with Starship Addendum.” OPR-2025-00164. https://repository.library.noaa.gov/view/noaa/70071
21. Kerr, D. (2025, July 17) “Inside Elon Musk’s plan to rain SpaceX’s rocket debris over Hawaii’s pristine waters”. Guardian. https://www.theguardian.com/technology/2025/jul/17/hawaii-elon-musk-spacex-rocket-debris
22. Berger, E. (2025, July 18). “Rocket Report: SpaceX won’t land at Johnston Atoll; new North Sea launch site” Ars Technica. https://arstechnica.com/space/2025/07/rocket-report-avio-celebrates-independence-pld-outlines-grand-ambitions/
23. Page 42 https://www.transportation.gov/sites/dot.gov/files/2024-03/FAA_FY_2025_Budget_Budget_Request.pdf
24. https://csps.aerospace.org/papers/spaceportopia-primer-successful-launch-site-planning
25. The average number of mitigation measures is 5–7.
26. PL 92-583. https://www.congress.gov/92/statute/STATUTE-86/STATUTE-86-Pg1280.pdf
27. https://www.boem.gov/environment/environmental-assessment/coastal-zone-management-act
28. Roulette, J., Bryan-Low, C. and Balmforth, T. (25 July 2025). “Musk ordered shutdown of Starlink satellite service as Ukraine retook territory from Russia”. Reuters. https://www.reuters.com/investigations/musk-ordered-shutdown-starlink-satellite-service-ukraine-retook-territory-russia-2025-07-25/